GMSA Investments Limited. RTS 28 Disclosure Report Calendar Year Disclosure Period: 1 January to 31 December 2017

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1 RTS 28 Disclosure Report Calendar Year Disclosure Period: 1 January to 31 December 2017 Introduction On an annual basis ( GMSA ) is required to provide additional disclosures around the execution venues utilised for each asset class and certain information on the quality of execution in line with the requirements of Regulatory Technical Standard 28 of the MiFID II regulation. The report has been compiled from 2017 trading data, which was subject to different regulatory obligations and as such is produced on a best efforts basis. As a consequence in some cases, information required to be reported under these regulations may not be available to BP Paribas or may contain an incomplete set of data. Annual qualitative disclosure on the quality of execution obtained for the purpose of RTS28/Art 65 (6) Disclosure Period: 1 st January December 2017 General observations When making and executing investment decisions, GMSA traders are required to act in good faith and in the best interests of their clients. With respect to execution, this is achieved by taking all sufficient steps, as required under the FCA rules, to obtain the best possible result for the clients, taking into account the relative importance of the Execution Factors below. GMSA monitors the effectiveness of its order execution arrangements to identify and, where necessary, corrects any deficiencies. There were no deficiencies identified during the reporting period. o single counterparty is favoured compared to others, unless it can be demonstrated that such counterparty consistently provides a superior service, which would include, for example, providing better pricing, liquidity or speed of execution than its competitors. There were no material changes to GMSA s execution (a) an explanation of the relative importance the firm gave to the execution factors of price, costs, speed, likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution Registered in England o arrangements during the reporting period. In circumstances where trades fall inside the scope of best execution under MiFID, the ranking of the Execution Factors will typically be as follows: Price Speed and/or likelihood of execution The impact on market prices of executing an order or part of Likelihood of settlement

2 (b) a description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders; (c) a description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or nonmonetary benefits received; (d) an explanation of the factors that led to a change in the list of execution venues listed in the firm s execution policy, if such a change occurred; (e) an explanation of how order execution differs according to client categorisation, where the firm treats categories of clients differently and where it may affect the order execution arrangements; (f) an explanation of whether other criteria were given precedence over immediate price and cost when executing retail client orders and how these other criteria were instrumental in delivering the best possible result in terms of the total consideration to the client; (g) an explanation of how the investment firm has used any data or tools relating to the quality of execution, including any data published under Delegated Regulation (EU) 2017/575 [RTS 27] (h) where applicable, an explanation of how the investment firm has used output of a consolidated tape provider Any other consideration relevant to the efficient execution of the order. The remaining Execution Factors, such as costs, nature of the order and other considerations relevant to the efficient execution of Client transactions are generally given equal ranking. However, where Clients gave the Firm specific instructions as to how they require the transactions to be executed, the duty of best execution was limited to those matters which are not covered by specific instructions. The Firm trades with an affiliate, Global Securities SAM of which GMSA owns 20% The Firm does not receive payments, discounts, rebates or non-monetary benefits in its trading arrangements. Counterparty banks and venues remain on our list of execution venues subject to an authorisation and ongoing monitoring process, which includes, but is not limited to, the counterparty s credit worthiness and financial stability, performance of execution and suitability in relation to the overall execution process All clients are treated the same. /A as GMSA is not permitted to trade with Retail customers. GMSA did not use any third party data and/or tools relating to quality of execution during the relevant period. GMSA utilises a number of in house processes to analyse the quality of its execution arrangements. The firm will review data issued by other execution venues under RTS 27 once such data information becomes available. GMSA does not currently use any consolidated tape provider for analysis of best execution, but will monitor the availability of such providers and the quality of information provided as part of on-going reviews of our best execution arrangements. Registered in England o

3 CLASS OF ITRUMET OTIFICATIO IF < 1 AVERAGE TRADE PER BUSIESS DAY I PREVIOUS YEAR TOP 5 EXECUTIO VEUES PROPORTIO OF PROPORTIO OF RAKED I TERMS OF TRADIG VOLUME TRADED AS ORDERS EXECUTED VOLUMES (DESCEDIG ORDER) % OF TOTAL I THAT AS % OF TOTAL I DEUTSCHE BAK AG- 7LTWFZYICSX8D621K % Debt Instruments CITIGROUP GLOBAL MARKETS LTD- XKZZ2JZF41MRHTR1V % GOLDMA SACHS International (GSI) - W22LROWP2IHZBB6K % UBS Limited (London)- BFM8T61CT2L1QCEMIK % J.P. MORGA SECURITIES LTD- K6Q0W1PS1L1O4IQL9C % Registered in England o

4 CLASS OF ITRUMET OTIFICATIO IF < 1 AVERAGE TRADE PER BUSIESS DAY I PREVIOUS YEAR TOP 5 EXECUTIO VEUES PROPORTIO OF PROPORTIO OF RAKED I TERMS OF TRADIG VOLUME TRADED AS ORDERS EXECUTED VOLUMES (DESCEDIG ORDER) % OF TOTAL I THAT AS % OF TOTAL I Cowen Execution Services LLC RJDJD18OPUP27 100% Equities CLASS OF ITRUMET OTIFICATIO IF < 1 AVERAGE TRADE PER BUSIESS DAY I PREVIOUS YEAR TOP 5 EXECUTIO VEUES PROPORTIO OF PROPORTIO OF RAKED I TERMS OF TRADIG VOLUME TRADED AS ORDERS EXECUTED VOLUMES (DESCEDIG ORDER) % OF TOTAL I THAT AS % OF TOTAL I Cowen Execution Services LLC RJDJD18OPUP27 100% Exchange Traded Products Registered in England o

5 CLASS OF ITRUMET OTIFICATIO IF < 1 AVERAGE TRADE PER BUSIESS DAY I PREVIOUS YEAR TOP 5 EXECUTIO VEUES PROPORTIO OF PROPORTIO OF RAKED I TERMS OF TRADIG VOLUME TRADED AS ORDERS EXECUTED VOLUMES (DESCEDIG ORDER) % OF TOTAL I THAT AS % OF TOTAL I Berkeley Futures Ltd GWMSRCJYDTHO27 74% Interest Rate Derivatives Banca IMI S.P.A - QV4Q8OGJ7OA6PA8SCM14 26% CLASS OF ITRUMET OTIFICATIO IF < 1 AVERAGE TRADE PER BUSIESS DAY I PREVIOUS YEAR TOP 5 EXECUTIO VEUES PROPORTIO OF PROPORTIO OF RAKED I TERMS OF TRADIG VOLUME TRADED AS ORDERS EXECUTED VOLUMES (DESCEDIG ORDER) % OF TOTAL I THAT AS % OF TOTAL I Berkeley Futures Ltd GWMSRCJYDTHO27 74% Equity Derivatives Banca IMI S.P.A - QV4Q8OGJ7OA6PA8SCM14 26% Registered in England o